Last November, the NCUA Board issued its proposed rule on field of membership. On Oct. 27, having received approximately 11,000 comment letters, the NCUA is coming full circle. The agency is scheduled to finalize its field of membership proposal and propose a new field of membership rule.
If the NCUA addresses many of the concerns NAFCU and our members have submitted to the agency, the new FOM rule will help ease some of the stifling regulatory burden that hinders credit unions’ ability to develop and serve their communities. Clearly, consumers are interested in credit unions — membership has reached nearly 105 million — and credit unions would like to serve more but are prevented from doing so based on existing regulations.
By any standard, these changes are long overdue.
The NCUA’s proposal represents the first major review of the common-bond requirements related to community, multiple-group and trade, industry or profession charter types in more than 10 years.
In today’s challenging competitive marketplace, NAFCU supports the NCUA’s FOM rule as a necessary measure that will allow credit unions to keep pace with state law changes as well as technology and the progress of the financial services industry. We believe the NCUA is acting well within its legal authority to remove non-statutory constraints on chartering and FOM expansion, and to streamline its procedures.
While last year’s proposed FOM rule was a solid step forward, NAFCU has also urged that more be done to give the industry regulatory relief, including: Eliminating or substantially increasing the core-based statistical area population cap, establishing a formal notification process for credit unions making FOM-related applications, and considering new ways to efficiently authorize mergers. We hope Thursday’s final rule and subsequent proposal deal with the issues that NAFCU and our members have communicated throughout the public comment period.
In the end, we look forward to reviewing the NCUA’s final and new proposed FOM rules. We appreciate the agency’s thoughtful approach to addressing this critical issue and hope this approach will be reflected in the finished rule.
Credit unions have been stymied in their efforts to be more competitive and extend services to many who would greatly benefit from them. Consumers merit the choice of a financial institution that puts them first. We hope the NCUA’s new FOM rule will help make that a reality.
B. Dan Berger is president/CEO of NAFCU. He can be reached at 703-522-4770 or dberger@nafcu.org.
